Lumi Privacy Policy

Last updated: October 4, 2026

Lumi is designed to help you organize, understand and plan your financial life.

We understand that the information you put into Lumi can be deeply personal. Your financial position, assets, investments, income, spending, property and goals are information that you should be able to control.

This Privacy Policy explains what personal information Lumi collects, how we use it, how we protect it, and the choices you have.

We aim to keep this policy clear and easy to understand.

We collect information that you choose to provide when using Lumi.

Account Information

This may include:

  • Name
  • Email address
  • Login and authentication information
  • Account preferences
  • Language and currency preferences

Financial Information

Depending on how you use Lumi, you may provide information about:

  • Cash and savings
  • Investments
  • Stocks, funds and other securities
  • Cryptocurrency
  • Properties
  • Vehicles and other assets
  • Mortgages and other liabilities
  • Income
  • Spending
  • Savings
  • Debt repayments
  • Financial goals
  • Asset ownership
  • Other financial information you choose to record

Household Information

If you use Lumi's household features, you may provide information about:

  • Household members
  • Ownership of assets
  • Shared assets and liabilities
  • Household income and spending
  • Other information you choose to include in your household financial picture

Information About How You Use Lumi

We may collect information about how you interact with the service, such as:

  • Features you use
  • Pages or screens you access
  • Actions you take within the application
  • Device and browser information
  • Technical information needed to operate and secure Lumi
  • Error and diagnostic information

We only collect information that is reasonably necessary for the purposes described in this Privacy Policy.

Lumi is designed around information that you choose to provide.

You may manually enter, edit or upload financial information to create your financial picture.

You are responsible for ensuring that the information you provide is accurate and that you have the right to provide any information about other people that you add to Lumi.

Lumi does not independently verify the financial information you provide.

Lumi does not directly connect to your bank accounts, brokerage accounts or other financial institutions.

Financial information in Lumi is information that you choose to enter, upload or otherwise provide to us.

This means you remain in control of what financial information you choose to put into Lumi.

We use your information to provide Lumi and its features.

This includes:

Providing Your Financial Overview

We use the information you provide to organize your financial life and display information such as:

  • Net worth
  • Assets
  • Liabilities
  • Cash flow
  • Savings
  • Asset allocation
  • Financial goals
  • Historical changes

Creating Calculations and Projections

We may use the information you provide to calculate metrics, projections and scenarios.

For example, Lumi may calculate:

  • Changes in net worth
  • Savings rates
  • Asset allocation
  • Debt balances
  • Goal progress
  • Future wealth projections

Providing Insights

Lumi may analyze information in your account to highlight patterns, changes or relationships in your financial information.

For example, Lumi may identify changes in savings, asset concentration or progress toward a financial goal.

Operating Lumi

We use information to:

  • Create and maintain your account
  • Authenticate users
  • Provide customer support
  • Maintain and improve the service
  • Detect and prevent abuse
  • Protect the security of Lumi
  • Diagnose technical problems
  • Communicate important information about the service

Legal Requirements

We may process information when necessary to comply with applicable laws, regulations, legal processes or lawful requests.

Where applicable under the GDPR and other relevant data protection laws, we process personal information based on one or more of the following legal bases.

Performance of a Contract

We process information when it is necessary to provide Lumi and the features you have requested.

For example, we need your account information and financial information to provide your financial overview.

Legitimate Interests

We may process information when it is necessary for our legitimate interests, such as:

  • Maintaining and securing Lumi
  • Preventing fraud and abuse
  • Improving the reliability of the service
  • Understanding how the service is used
  • Providing customer support

When relying on legitimate interests, we consider whether those interests are balanced against your rights and freedoms.

Consent

Where required, we may ask for your consent before processing information for a particular purpose.

When processing is based on consent, you may withdraw your consent at any time.

Legal Obligations

We may process information when necessary to comply with a legal obligation.

Financial information can be highly personal, and we treat it accordingly.

We use your financial information to provide Lumi's financial organization, visualization, planning and insight features.

We do not sell your financial information.

We do not use your financial information to determine whether you should receive credit, insurance, employment or other services.

Lumi is not a bank, broker, lender, investment manager or financial institution.

Lumi does not execute financial transactions or move money on your behalf.

Information, projections and insights provided by Lumi are based on the information and assumptions available in your account.

They are provided for informational and planning purposes and should not be considered financial, investment, tax or legal advice.

Lumi may allow you to create a combined view of your household finances.

For example, you may choose to record assets, liabilities or income belonging to different members of your household.

If you provide personal information about another person, you are responsible for ensuring that you have an appropriate legal basis or permission to provide that information to Lumi.

You should not provide information about another person where you do not have the right to do so.

We do not sell or rent your personal or financial information.

We may share information with service providers that help us operate Lumi.

These may include providers of:

  • Cloud infrastructure and hosting
  • Database services
  • Authentication
  • Security
  • Analytics
  • Error monitoring
  • Customer support
  • Communication services
  • Other technical services necessary to operate Lumi

These providers may process personal information on our behalf and only for purposes necessary to provide their services to us.

Where required, we enter into appropriate agreements with these providers and require appropriate confidentiality and security protections.

We may also disclose information where required by law, legal process or a valid request from a competent authority.

Some service providers used by Lumi may process information outside the European Economic Area.

Where personal information is transferred outside the EEA, we will use appropriate safeguards required by applicable data protection law.

These safeguards may include an adequacy decision by the European Commission or appropriate contractual safeguards.

We use technical and organizational measures designed to protect your personal information against:

  • Unauthorized access
  • Unauthorized disclosure
  • Loss
  • Destruction
  • Alteration
  • Misuse

We limit access to personal and financial information to people and service providers who reasonably need access to perform their role.

However, no internet service or method of electronic storage can be guaranteed to be completely secure.

You are also responsible for protecting your account credentials and keeping your login information confidential.

If you believe that your Lumi account has been compromised, please contact us at:

hello@15labs.dev

We keep personal information for as long as reasonably necessary to provide Lumi and fulfill the purposes described in this Privacy Policy.

The specific retention period depends on:

  • The type of information
  • Why we collected it
  • Whether you continue to use Lumi
  • Whether we have an ongoing legal or contractual obligation
  • Whether the information is necessary to resolve disputes or enforce agreements

When you delete your account, we will delete or anonymize your personal information within the applicable retention period, unless we are required or permitted by law to retain certain information.

Backup systems may retain information for a limited additional period before it is permanently deleted or overwritten.

Depending on where you live and applicable law, you may have rights including:

  • Access to your personal information
  • Correction of inaccurate or incomplete information
  • Deletion of your personal information
  • Restriction of certain processing
  • Objection to certain processing
  • Data portability
  • Withdrawal of consent where processing is based on consent
  • The right to lodge a complaint with a data protection authority

To exercise your privacy rights, contact:

hello@15labs.dev

Please provide enough information for us to understand your request and verify your identity where necessary.

We will generally respond to valid requests within the time period required by applicable data protection law.

In certain circumstances, we may need additional information to verify your identity or may be legally permitted to limit or refuse a request.

Lumi is currently in an early testing phase, and we are actively improving the product based on how people use it and what they tell us.

As part of this process, we may contact you using the contact information associated with your Lumi account to:

  • Ask for feedback about your experience
  • Invite you to participate in user research or product testing
  • Ask about features or workflows you would like to see
  • Ask questions about how Lumi could be improved
  • Invite you to test new or experimental features
  • Better understand how Lumi can be built around your needs

We want to build Lumi together with the people who use it, so your feedback may directly help shape future versions of the product.

Participation in research, interviews or testing is voluntary.

You can choose not to participate or ask us not to contact you for these purposes.

Lumi may use calculations, rules, algorithms or other automated processes to generate:

  • Financial summaries
  • Charts
  • Projections
  • Goal calculations
  • Financial insights
  • Other information derived from the information in your account

These processes are intended to help you understand your financial information.

Lumi does not use these processes to make decisions about your eligibility for credit, insurance, employment or similar services.

Where Lumi uses automated processing that would produce a legal or similarly significant effect on you, we will provide the information and rights required by applicable law.

Some Lumi features may use artificial intelligence or machine-learning technologies to help generate explanations, summaries or insights.

Where AI is used, we take steps designed to ensure that the processing is consistent with the purposes described in this Privacy Policy.

Your financial information is not sold to AI providers.

Where third-party AI services are used to provide a Lumi feature, information shared with those services will be subject to appropriate contractual, security and data protection safeguards.

We will provide additional information where required about significant AI-enabled processing.

Lumi may use cookies and similar technologies that are necessary to:

  • Operate the service
  • Maintain sessions
  • Remember preferences
  • Protect accounts
  • Understand technical performance

Where applicable law requires consent for non-essential cookies or similar technologies, we will request that consent before using them.

You may be able to manage certain cookie preferences through your browser or Lumi's cookie settings.

Lumi is intended for adults.

We do not knowingly collect personal information from children where such collection is prohibited by applicable law.

If you believe that a child has provided personal information to Lumi without appropriate authorization, please contact us at:

hello@15labs.dev

Lumi may evolve over time, and this Privacy Policy may therefore change.

When we make changes, we will update the "Last updated" date at the top of this policy.

If a change materially affects your rights or how we process your personal information, we will provide appropriate notice before or when the change takes effect, where required by law.

For questions about this Privacy Policy, your personal information, or your privacy rights, please contact:

hello@15labs.dev